Philippine Skylanders vs NLRC

G.R. No. 127374, Jan. 31, 2002

FACTS:

 In November 1993 the Philippine Skylanders Employees Association (PSEA), a local labor union affiliated
with the Philippine Association of Free Labor Unions (PAFLU), won in the certification election conducted
among the rank-and-file employees of Philippine Skylanders, Inc. (PSI). Its rival union, the Philippine
Skylanders Employees Association-WATU (PSEA-WATU) immediately protested the result of the
election before the Secretary of Labor. Several months later, PSEA sent PAFLU a notice of disaffiliation.
 PSEA subsequently affiliated itself with the National Congress of Workers (NCW), changed its name to
Philippine Skylanders Employees Association – National Congress of Workers (PSEA-NCW), and to
maintain continuity within the organization, allowed the former officers of PSEA-PAFLU to continue
occupying their positions as elected officers in the newly-formed PSEA-NCW.
 On 17 March 1994 PSEA-NCW entered into a collective bargaining agreement with PSI which was
immediately registered with the Department of Labor and Employment.
 Meanwhile, apparently oblivious to PSEA’s shift of allegiance, PAFLU Secretary General Serafin Ayroso
wrote Mariles C. Romulo requesting a copy of PSI’s audited financial statement. On 30 July 1994 PSI
through its personnel manager Francisco Dakila denied the request citing as reason PSEA’s disaffiliation
from PAFLU and its subsequent affiliation with NCW.

ISSUE:

 W.O.N PSEA’s disaffiliation is legitimate.

HELD:

 YES. PSEA may validly disaffiliate from PAFLU pending the settlement of an election protest questioning
its status as the sole and exclusive bargaining agent of PSI's rank and file employees. There is nothing
shown in the records nor is it claimed by PAFLU that the local union was expressly forbidden to disaffiliate
from the federation nor were there any conditions imposed for a valid breakaway. As such, the pendency of
an election protest involving both the mother federation and the local union did not constitute a bar to a
valid disaffiliation. Neither was it disputed by PAFLU that 111 signatories out of the 120 members of the
local union, or an equivalent of 92.5% of the total union membership supported the claim of disaffiliation
and had in fact disauthorized PAFLU from instituting any complaint in their behalf.
 Policy considerations dictate that in weighing the claims of a local union as against those of a national
federation, those of the former must be preferred. Parenthetically though, the desires of the mother
federation to protect its locals are not altogether to be shunned. It will however be to err greatly against the
Constitution if the desires of the federation would be favored over those of its members. That, at any rate, is
the policy of the law. For if it were otherwise, instead of protection, there would be disregard and neglect of
the lowly workingmen.